I apologize but I need to verify the timing requirements. If I deliver an appraisal in person on Monday, then I can close the loan on Thursday?
If I mail the appraisal on Monday though, when can I close the loan?

4. Timing. Section 1002.14(a)(1) requires that the creditor "provide" copies of appraisals and other written valuations to the applicant "promptly upon completion," or no later than three business days before consummation (for closed-end credit) or account opening (for open-end credit), whichever is earlier.

i. For purposes of this timing requirement, "provide" means "deliver." Delivery occurs three business days after mailing or delivering the copies to the last-known address of the applicant, or when evidence indicates actual receipt by the applicant, whichever is earlier. Delivery to or actual receipt by the applicant by electronic means must comply with the E-Sign Act, as provided for in § 1002.14(a)(5).


3 + 3 = 6

This was a post from 10/23/14 titled Counting Days Before Close. If I mail on Monday then I must wait 6 business days to close?

If I mail an appraisal report, would I do a 3 day presumption of receipt? And then count 3 additional days for the ECOA Appraisal Rule, earliest consummation date being on the 7 business day from when I mailed the Report?

i. For purposes of this timing requirement, "provide" means "deliver." Delivery occurs three business days after mailing or delivering the copies to the last-known address of the applicant, or when evidence indicates actual receipt by the applicant, whichever is earlier. Delivery to or actual receipt by the applicant by electronic means must comply with the E-Sign Act, as provided for in § 1002.14(a)(5).


You do not have a 3 + 3 with the delivery of the appraisal as you do with the providing a revised ETIL by mail.

It appears I made a typo in that post that no one caught.

http://www.bankersonline.com/forum/ubbth...558#Post1979558

4. says I have to provide (deliver) the appraisal at least 3 business days before consummation. i. says if I mail the appraisal it is not considered delivered (provided) until 3 days later and once it's delivered (provided) then there is another 3 day waiting period before consummation.

If the lender delivers the free copy in person to the applicant on Monday the loan may be closed on Thursday. However, if mailed on Monday the loan may not be closed until the following Monday (assuming you count Saturday as a Business day). The idea is that the free copy must be "in hand" three days before closing.

And just to add a little more fuel to this discussion, I predict that the greater risk of non-compliance is the appraisal that's completed, and the copy isn't provided promptly. With all the focus on the days before consummation, lenders may forget that Reg B's appraisal copy rule (unlike it distant cousin the HPML appraisal copy rule) uses a two-pronged requirement: It must be provided promptly upon completion of the appraisal, but no later than three business days prior to consummation or account opening.